AML compliance for micro-cap forex brokers operating in multiple jurisdictions
I'm still wrapping my head around the nuances of AML compliance for smaller forex brokers, particularly those that might not have the massive legal departments of the tier-1 firms but still operate across several jurisdictions. My specific question is about the practicalities of a unified risk-based approach when different regulators (say, CySEC vs. a smaller offshore regulator) have slightly varying interpretations of 'high-risk' clients or transaction monitoring thresholds. Do you generally try to meet the highest common denominator across all your operational jurisdictions, or do you tailor your AML program specifically to each region, leading to more fragmented internal policies? How do others manage this without ballooning operational costs?
It's less about a unified approach and more about ensuring your most stringent jurisdictional requirements are met across the board, then layering on the others. Trying to average it out is where the compliance gaps appear.